Privacy policy

1. Who we are

LUCIDi4 Limited (“we”, “us”) is a company registered in Hong Kong SAR. We act as a data controller in respect of the personal data described in this policy. Our registered business address and Business Registration number are available on request at enquiries@lucidi4.co.

2. What data we collect

We collect (a) contact data you provide when you enquire about an engagement — typically name, employer, email address, country of operation, and a written description of your brief; (b) engagement data we collect during a client project, which may include operational information the client shares with us; and (c) billing data necessary to raise and receive payment against agreed fees.

3. How we use it

Contact data is used to respond to enquiries and, where relevant, to propose an engagement. Engagement data is used only to deliver the agreed scope of work. Billing data is used to raise invoices, collect payment, meet our record-keeping obligations, and pursue recovery of unpaid fees where necessary.

4. Legal basis

We process personal data on the basis of (i) the contract we have or are negotiating with the data subject or their employer, (ii) our legitimate interest in operating and developing our professional practice, and (iii) our statutory obligations — including those under the Hong Kong Companies Ordinance, the Inland Revenue Ordinance, and the Personal Data (Privacy) Ordinance.

5. Sharing

We do not sell personal data. We share it only with (a) sub-processors acting on our documented instructions — our email provider, our accounting software, and our payment processor; (b) professional advisors such as our accountants and legal counsel; and (c) authorities where we are required to do so by law.

Our payment processor is Airwallex (Hong Kong) Limited, which receives the minimum data needed to process a payment: name, email address, and billing country. The payment processor is solely responsible for the handling of card data, which never touches our own systems.

6. Retention

Contact data from unsuccessful enquiries is retained for 24 months and then deleted. Engagement and billing records are retained for seven years after the close of the engagement, to meet our Hong Kong tax and companies-law record-keeping obligations. Thereafter they are deleted.

7. International transfer

Our email, accounting, and payment-processing sub-processors may store data outside Hong Kong. We rely on the contractual protections provided by those sub-processors and, where applicable, on their own certifications and transfer frameworks.

8. Your rights

You may ask us to confirm what personal data we hold about you, correct it, or delete it, subject to the limits of our statutory record-keeping obligations. Write to enquiries@lucidi4.co. We aim to respond within 30 days.

9. Complaints

If you believe we have mishandled your personal data you may contact the Office of the Privacy Commissioner for Personal Data, Hong Kong.

10. Changes

We may update this policy from time to time. The version in force is the version published on this page.